Liquid crystal devices classification under heading 9013 prevails over residual parts heading for instrument cluster LCD modules.

LCD modules imported for use in instrument clusters were treated as liquid crystal devices classifiable under heading 9013, because the tariff heading specifically covers such devices and Chapter 90 Note 2(a) requires goods falling within a specific heading to be classified there rather than as parts under a residual heading. The analysis followed the earlier Supreme Court approach on similar LCDs and rejected classification under heading 9029 for speedometer parts and accessories. The challenged classification was also criticised as lacking technical support and as having been made without a show cause notice. The lower classification was therefore unsustainable.

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Issues: Whether LCD modules imported for use in instrument clusters were classifiable under heading 9013 as liquid crystal devices or under heading 9029 as parts and accessories of speedometers.

Analysis: The imported goods were found to be LCD modules used in instrument clusters for displaying kilometer reading, trip reading and clock. The classification had to be determined by the terms of the heading and the chapter notes. Liquid crystal devices are specifically covered by heading 9013, and Note 2(a) to Chapter 90 requires goods already falling within a specific heading of the chapter to be classified in that heading rather than being pushed into a parts heading. The reasoning adopted in the earlier Supreme Court ruling on similar LCDs was followed, and the residual parts heading under 9029 could not override the specific coverage of LCDs under 9013. The order under challenge was also unsupported by technical opinion and was passed without a show cause notice.

Conclusion: The goods were classifiable under heading 9013 and not under heading 9029. The classification adopted by the lower authorities was unsustainable.

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